Regulatory Challenges of Sterile Formulation Development As Per USFDA Prospectives

 

Satheesh S*, S Abimanyu, R. Kamaraj

Department of Pharmaceutical Regulatory Affairs, SRM College of Pharmacy, SRM Institute of Science and Technology, Kattankulathur-603203, Kanchipuram, Tamil Nadu, India

*Corresponding Author E-mail: satheeshsatz445@gmail.com

 

ABSTRACT:

For the sterile product development FDA has taken many initiatives for the safety and efficacious products. Recently, many works have been done for the improvement in drug development. Quality by Design (QBD) Product and manufacturing process development, as well as safe use and product design, are among the elements of enhanced technical involvement. In this review, we discussed an overview of regulatory challenges to improve the quality aspects for sterile drugs. FDA has regulated current good manufacturing practice (CGMP) regulations for the manufacture of large volume parenterals. The studies can then be prolonged to multiple ingredients to assure compatibility with the API and each of the excipients. The compatibility of the drug product should provide appropriate information about the drug product. It should deals with the quality of drug product and route of administration for the intended use. Microbiological review conducted in 1970-1971 for the manufacture of sterile drug was one of FDA’s responses to the nosocomial bacteremias, Recently the new drug microbiology review function has been re-examining its role in non-sterile dosage forms in order  to Know about recalls and adverse event for oral and topical drug products.  For the Active pharmaceutical ingredient justifying the quality source is generally time-consuming effort whether the product is manufacturein-house, as with an Non chemical entity, or sourced externally, as with a generic API.5

 

KEYWORDS: Sterile formulation, Active pharmaceutical ingredient, Compatibility, drug product, Recipients.

 

 


INTRODUCTION:

The Sterile product development studies can be conducted in various route of administration, be it an, intramuscular, intravenous, subcutaneous, ophthalmic, subcutaneous, intra-articular, intrathecal, or inhalation product. the product must be registered with new chemical entity (NCE) filed as a 505(b) (1) Application for approval of a new drug application (NDA), Application for approval of a new drug that relies, at least in part data not developed by the applicant 505(b) (2) NDA, or Application for approval of a generic drug product505(j) abbreviated NDA (ANDA).

 

“The required studies are also the same for veterinary drugs registered as new entities filed as new animal drug applications (NADA) or as generics filed as abbreviated new animal drug applications (ANADA)”. In the review we are focussing about the current regulatory challenges related to safety and efficacy of the parentral product. For the sterile product development FDA has taken many initiatives for the safety and efficacious products. Microbiological review conducted in 1970-1971 for the manufacture of sterile drug was one of FDA’s responses to the nosocomial bacteremias, Recently the new drug microbiology review function has been re-examining its role in non-sterile dosage forms in order  to Know about recalls and adverse event for oral and topical drug products2.

 

There are various route of administration either by direct injections, for example, intramuscular (IM) intravenous (IV), or subcutaneous (SC), or by infusion with a controlled infusion rate or by direct implantation through SC or IM.

There are two types:

Small volume parentrals are known simply as SVPs – are sterile solution that typically have a volume of 25ml 50ml and 100ml In general these solution are neutral isotonic and isosmotic.

 

Large Volume parentrals are known simply as LVPs- are sterile solution that typically have a large volume of 100ml to 1000ml.

 

It must comes under FDA requirement

“It should be sterile and pyrogen-free; To be clear or practically exempt of visible particle and to be free from sub-visible particles as required by pharmacopoeias EP, USP and JP; No evidence of phase separation for the emulsions, or aggregates formation for aqueous dispersion such injectable Mab (monoclonal antibody) preparations; and In the case of suspensions, the use of appropriate particle size and any sediment should be readily dispersed upon shaking to give stable formulations and ensure the correct dose to be withdrawn and injected”

 

CHALLENGES IN PARENTRAL FORMULATION DEVELOPMENT:

“The main challenge of all the different parenteral dosage forms is to achieve a good compatibility of the drug substances with the excipients—no formation of new impurities either by degradation of the drug substance or formation of new chemical entity between the drug substance and the excipients-as well as the compatibility of the preparation”.

 

During shelf life of drug products the drug substance involved in the preparation should be soluble and it should contain specific amount of prodrug or surfactants or use of solubility enhancers such as cyclohexdrins.

 

“Finally the process of the sterilization should be selected according to the characteristics of the parenteral preparations. For instance, heat steam sterilization for aqueous solutions and dry heat for non-aqueous solutions, but in any case it can be justified by the nature of the primary containers.4 It display the decision trees for the selection of the sterilization process for aqueous products or non-aqueous solutions including semi-solid and dry powder products”.

 

Sterilization process efficiency can be determined by validation studies, using the suitable biological indicators, to ensure an ASL (Assurance Sterility level) of 10-64.

 

RAW MATERIALS- SELECTION CRITERIA

For the Active pharmaceutical ingredient knowing about the physiochemical properties is essential. “This understanding provides descriptions of the primary structure of the solubility, molecule, water content, impurity types, and crystal structure, as well as the secondary/tertiary/quaternary structures for biotechnology products”. The type of testing comes under this criteria is mentioned in Q6A guidance.

 

Example: “Most small molecule products are solutions, but crystal structure may impact solubility selecting the wrong polymorph could result in prolonged mixing times or other process deviations. For a suspension, where solubility directly impacts bioavailability, erratic dosing and efficacy could result”.

 

Excipient selections for the raw material selection are also to be anguished. API compatibility should be discussed based on the the justification for use. For that it should be chose based upon its usage. The List of excipients are bulking agents, buffers tonicity adjusters, antimicrobials, stabilizers, and antioxidants. viscosity should be controlled by the formulator or other attributes1

 

When one or two excipients deals with the drug substance in compatibility studies should provide wonderful information about the interaction of the excipients with the API. “The studies can then be prolonged to multiple ingredients to assure compatibility with the API and each of the excipients. Excipient levels must be maintained within a functional concentration, reflecting the levels at which they will be used in a formulation. Later studies are then performed to demonstrate that the final level chosen is appropriate by exploring concentrations above and below the proposed concentration.

 

MANUFACTURING PROCESS:

When the preliminary formulation has been found, the overall manufacturing process should be explained. It should deals with the required mixing speeds and addition of ingredients. It must follow appropriate method of sterilization for the primary packaging material and drug products should be preferred for those products intended to be sterile

 

“The ultimate goal of any process development activity is the production of a viable commercial product. Thus, a robust process that can be smoothly scaled up to commercial scale and executed reproducibly is a necessity. A process that is not robust will give rise to process deviations and out of specification test results (i.e., rejected batches). Even worse, a poorly developed process can lead to recalls putting patients unnecessarily at risk”.

 

Thus, both the process engineer and formulator should always focus on the end product being given to the patient. “The formulator and process engineer must continuously compile comprehensive developmental data. It is necessary to compile all activities and data is critical throughout the entire development program based on patient safety and in preparation for regulatory inspection. The proper qualification, maintenance, and calibration of development equipment must always be considered”. For the human phase 1 studies the candidates can be used in the Non chemical entity, all the work should be done in a compliant manner. “Even pre formulation work should be conducted using good scientific practices such as equipment IQ/OQ, formal calibration, maintenance, and good documentation”.

 

It should follows,

·       Manage reliable and secure supply chain

·       Maintain risk mitigated, reliable and efficient manufacturing operation

·       Provide safe efficacious and detect free high quality drug product1

 

RAW WATER CHALLENGES IN STERILE FORMULATION:

1.     Purified Water also to be used for all tests and assays for which water is mentioned.

2.     Purified Water must fulfil the usage of ionic and organic chemical purity and should be protected against microbial contamination.

3.     The minimum quality of source or feed water for the production of Purified Water is Drinking Water.

4.     For the production of non parentral preparation purified water is used as the excipient.

 

Procedure to reconstitute the drug product (if applicable):

1.     For the biological drug product Specific handling instructions must be noted (shaking, shear)

2.     To maintain specific concentration for a drug product.

3.     To maintain storage condition for a drug product

4.     IV container should be in appropriate size.

5.     The Studies comes under the section should play the specific role about regulatory  requirement.

 

CONTAINER/CLOSURE SYSTEMS:

Product stability can be affected by the primary packaging components. The container/closure system may also have the chance to impact stability “Polymers have materials that can extract into the formulation causing precipitation or degradation. Stability can be affected by moisture permeability and oxygen of these materials.

 

The choice of primary packaging should deals with e.g., Choice of materials, protection from light and moisture Compatibility of the materials construction with the dosage form and safety of materials of construction. It should justify the choice of material used for primary packaging. The discussion should deals with the studies to demonstrate the integrity of container and closure. A possible interaction between product and label or container should be discussed4

 

It should follows,

It should be treated like CCS for sterile finished drug product

 

Container used for the sterile formulation must be neutral towards it.

 

The container should not interact with the substance physically or mentally which it holds.

 

CASE STUDIES:

“Your firm failed to establish and follow appropriate written procedures that are designed to prevent microbiological contamination of drug products purporting to be sterile, and that include validation of all aseptic and sterilization processes (21 CFR 211.113(b))”.

 

“Significant airflow turbulence, including air moving in an (b)(4) direction, in the laminar airflow (LAF) unit in which aseptic (b)(4) and tubing connections are made for the (b)(4) process. Also, the studies lacked dynamic simulation of this critical intervention”. 

 

No dynamic smoke studies to be determined by unidirectional airflow during the manual aseptic transfer of (b)(4) units into the (b)(4) used for transport to the (b)(4)”.

 

“Inadequate evaluation of airflow patterns in your stopper (b)(4) area, and turbulence around the stopper (b)(4)”.

 

Operators (b)(4) open filled vials when altering the stopper (b)(4), which is harmfull to sterility assurance.

 

“Without smoke study data to demonstrate unidirectional airflows over all aseptic operations and processing steps, you cannot show that your processes are designed to prevent microbiological contamination or provide adequate assurance of product sterility”.

 

IN RESPONSE:

1.     To avoid contamination of sterile drug products the room should be cleaned

2.     Epoxy flooring should be there to avoid any dust particle storage

3.     Dynamic airflow visualization study and smoke pattern testing should be conducted to minimize the risk

4.     The stopper should provide proper airflow pattern

5.     The open filled vials like ampoules should be closed perfectly without giving a chance of contamination

 

 

ANALYTICAL CHALENGES:

For the administration studies it is classified into highest dose and the lowest dose to be given in the clinic. “While the upper concentration limit may be in the same order of magnitude as the concentration of the undiluted drug product and therefore usually not challenging from an analytical perspective, the lower concentration limit could occasionally be much lower than the analytical level of quantification. As an example for biological products such as monoclonal antibodies, the lower concentration limit of 0.05 mg/ml may be challenging from analytical perspective”. In such scenarios, certain adjustments should be needed for the dosing plan or analysis. For low dose levels, IV container administration volume should need to be minimize with appropriate concentration

 

Sample replicates. The samples used for optimization of measurement should give the correct value. “In practice, though, this may lead to a significant increase in the number of samples and drug product requirements. Therefore, duplicate samples may be a viable option. In the cases where the duplicate sample loads are still too high, average sample composites may be considered. In such a situation, the actual analytical sample will be a composite of two or more individual samples prepared in the same way”. When an individual sample is tested, it will be reflected1.

 

Sample storage testing. “In certain cases where the samples cannot be tested immediately, or if the samples are required to be shipped to different testing sites, they may be frozen to minimize changes. However, a probe study or prior experience should be used to evaluate the effect of freezing on sample stability”.

 

Diluent impurities “Certain impurities may be seen in some diluents which can interfere with the analytical techniques employed to test admixture samples. For example, 5-hydroxymethylfurfural or related substances in Dextrose Injection, USP solution are degradation products of dextrose and absorb UV light (~280 nm), thus interfering with the UV A280 concentration measurements”

 

REGULATORY REQUIREMENT:

Regulatory agencies have discussed about the drug product registration requirements. For an example the “ICH Harmonized Tripartite Guideline—Pharmaceutical Development Q8” describes the following: “The compatibility of the drug product with reconstitution diluents (e.g., precipitation, stability) should be addressed to provide appropriate and supportive information for the labeling. This information should cover the recommended in- use shelf life, at the recommended storage temperature and at the likely extremes of concentration.

Likewise, admixture or dilution of products prior to administration (e.g., product added to large volume infusion containers) might need to be addressed” (ICH 2009 ). For the Administration section and Dosage of labelling required under 21 CFR 201.57(c)(3) as mentioned in the Guidance for Industry document titled “Dosage and Administration Section of  Labeling for Human Prescription Drug and Biological Products—Content and Format” (US Department of Health and Human Services and Drug Administration

 

Surface incompatibilities. “Another challenge associated with admixture solutions which is especially critical at low concentration levels is the potential for drug losses due to adsorption (small amount of drug in contact with entire container surface). At high dilution ratios the concentration of surfactant, if present in the drug product may also fall below critical micelle concentration, making the drug loss at surfaces even more likely”. While the instability caused by the surface induced denaturation are added to it12

 

Diluents choice “The compatibility and stability studies must be made according to the requirements of the clinical program”. If any incompatibility occurs in the administration studies it help remove those choices. “In certain cases, the reformulation experience may also help eliminate some of the choices. For example, in the case of biologics, incompatibilities with sodium chloride may have been observed in the preformulation studies in the form of one or more of the following: increase in opalescence, particle formation, shaking stress instabilities, and/or soluble aggregate formation”. For that cases, normal saline is not consider as best choice of diluents. 

 

ICH Q8:  PHARMACEUTICAL DEVEOPMENT:

“The parameters required by the Health Authorities for ensuring quality during the registration of the product are outlined in the International Conference on Harmonisation (ICH) of Technical Requirements for Registration of Pharmaceuticals for Human Use guidance Q8 Pharmaceutical Development” (FDA Guidance for Industry 2009b).

 

The stated objective of the Q8 guidance follows.

The Q8 guidance gives an outline for the presentation of “the knowledge gained through the application of scientific approaches and quality risk management (as defined in ICH Q9 Quality Risk Management) to the development of a product and its manufacturing process.” The section is first generated for the original marketing application approved should be comes under good knowledge Accomplished for the lifecycle of a product. The Pharmaceutical Development section should provide should deals with the important aspects of the product and manufacturing process for reviewers and inspectors.”

The Q8 guidance “also indicates areas where the demonstration of greater understanding of pharmaceutical and manufacturing sciences can create a basis for flexible regulatory approaches.” According to the Q8 guideline, “The degree of regulatory flexibility is predicated on the level of relevant scientific knowledge provided”, For preclinical and clinical it should not deals with the guideline. As a result knowledge gained in these studies provide additional support4.

 

QUALITY BY DESIGN:

These Guidelines deals with various sections “Pharmaceutical Development report needed for the CTD required for the registration of a product. Each section of the outline is based on fundamental aspects of good science that a formulation development specialist normally addresses. In addition, Q8 provides a recommended plan for assessing risk by designing studies aimed at identifying critical process parameters (CPPs) and implementing appropriate controls to ensure consistent product quality”. The term often used is “Quality by Design” (QbD). The QbD philosophy gives an importance about the development scientist will design studies and give importance in all ways to maintain good quality finished product6.

 

QUALITY PARADIGM:

Product profile

 

CQA’s

 

Risk assessments

 

Design space

 

Control strategy

 

Continual improvement

 

ELEMENTS OF QBD:

Product process design and development:

 

Define desired product performance upfront and identify product CQA’s

 

Design Formulation and process to meet product CQA’s

 

Understand impact of material attributes and process parameters on product CQA’s

 

Identify and control source of variability in material and process

 

Continually monitor and update process to assure consistent quality

Risk Assessment and risk control

ACTIVE PHARMACEUTICAL INGRIDIENT:

API selection is probably mentioned to the formulator by the sponsoring company. “In most large pharmaceutical companies, the individual formulator is assigned an NCE and requested to create the appropriate formulation. In some smaller companies, it is the duty to the formulator to identify old drug products and reformulate them in a way that overcomes long-standing issues with old formulations”. In other companies, “the formulator may be assigned an old drug product and asked to reproduce the innovator company’s preparation with an aim toward the development of a generic product”.

 

For the Active pharmaceutical ingredient justifying the quality source is generally time-consuming effort whether the product is synthesized in-house, as with an Non chemical entity, or sourced externally, as with a generic API. “For small molecules, the salt form, polymorph/solvate, and impurity profile are among the first properties examined. The first properties considered for biotechnology compounds include a confirmation of the amino acid primary structure sequence and any secondary, tertiary, quaternary structures as well as labile linkages, etc. Structures”.

 

The solubility of the small molecular product of salt and crystal form, Which is discussed in various sections for the formulation approach. The product used in the process can also affect stability. For the formulation development API source is the key factor for the solubility.

 

“The impurity profile of the API must also be attended to. In addition to the Q6A guidance, ICH guidances Q3A (FDA Guidance for Industry 2008b), Q3B (FDA Guidance for Industry 2006a), and Q3D (FDA Guidance for Industry 2009a) provide direction in this area. Generally, impurities over 0.1% must be dealt with. Actions range from identification to toxicological qualification, depending on how high the impurity level is. In addition, ICH Q3C (FDA Guidance for Industry 2012) provides guidance for acceptable levels of residual solvents in the drug substance, as does USP”.

 

For the generic active pharmaceutical ingredients it provide additional challenges in the compilation of an impurity profile that deals with the parameters of innovator product. “In particular, the impurity levels must be compared to the brand product in order to assure that no new impurities are introduced. Therefore, samples from multiple vendors must be obtained and analyzed in order to determine which vendors of API are able to deliver the drug substance that can meet the previously established impurity profile observed in the innovator product”.

“Once the API source has been confirmed, more routine preformulation can begin in order to move toward the characterization of the physicochemical properties of the drug substance. These studies include expanding the database of solubility in various solvent systems as well as at various pH levels, depending on the ionic properties of the drug substance”.“The molecule’s tendency toward hydrolysis at various pH levels, thermal degradation, light instability, oxidation, and reduction are also examined. In addition, for biological molecules, preformulation also includes various studies such as amino acid sequencing, alpha-helix analysis, beta- sheet content analysis, sulfide linkage identification, glycosylation pattern characterization, and other evaluations that may affect formulation approaches and overall stability” FDA has regulated current good manufacturing practice (CGMP) regulations. The studies can then be prolonged to multiple ingredients to assure compatibility with the API and each of the excipients9.

 

CONCLUSION:

From the above study we have concluded that the sterility should be maintained according to the quality standards in the manufacturing unit and maintain good compatibility of the drug product so the drug should follows the quality guidelines. To reduce any type of contamination in various sterilization process this research has been conducted. For the manufacture of sterile product it should follow the FDA norms. So the main aim of the research to minimize the errors in the packaging areas, manufacturing unit, container closure system to produce high quality products that satisfies the customer according to their needs, here we discussed briefly about regulatory challenges in the sterile formulation

 

CONFLICT OF INTEREST:

The author does not declare any conflict of interest.

 

ACKNOWLEDGEMENT:

Authors want to acknowledge the management of SRM College of Pharmacy, SRM Institute of Science and Technology for their valuable support.

 

REFERENCE:

1.      Blad KD, Lookinland S, Measom G, Bond AE, Williams M (2000) Assessing dopamine concentrations:an evidence-based approach. Am J Crit Care 9(2):130–139

2.      Czuba L, Puryear H, Sarkar K (1996) An alternative to DEHP plasticized polyvinyl chloride in chemotherapy drug delivery systems. J Vinyl Additive Technol 2(4):314–320

3.      US Food and Drug Administration (2010) Safety assessment of di(2-ethylhexyl)phthalate (DEHP) released from PVC medical .devices. http://www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/UCM080457.pdf

4.      ICH (2009) ICH harmonized tripartite guideline—pharmaceutical development Q8. In: International conference on harmonization of technical requirements for registration of npharmaceuticals for human use. http://www.ich.org/fi leadmin/ Public_Web_Site/ICH_ Products/Guidelines/Quality/Q8_R1/Step4/Q8_R2_ Guideline.pdf .Accessed 2 Feb 2011

5.      Food and Drug Administration Current good manufacturing practice in the manufacture, processing, packing, or holding of large  volume parenterals—proposed rule. Federal Register. 1976;41(106):22202–18.

6.      Quality by design https://www.slideshare.net/shettyuc/qbd-for-beginners-introduction-13953395

7.      Casestudies https://www.google.com/search?q=open+filled+vials&rlz=1C1CHBF_enIN827IN827&oq=open+filled+vials&aqs=chrome..69i57.9424j0j7&sourceid=chrome&ie

8.      FDA Inspection and compliance https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/wockhardt-ltd-495920-12232016

9.      US Department of Health and Human Services, Food and Drug Administration (2010) Guidancefor industry. Dosage and administration section of labeling for human prescription drug and biological products—content and format. http://www.fda.gov/downloads/Drugs/Guidance Compliance Regulatory Information/Guidances/ucm075066.pdf .

10.   Food and Drug Administration Current good manufacturing practice in the manufacture, processing, packing, or holding of large volume parenterals—proposed rule. Federal Register. 1976; 41(106):22202–18.

11.   Regulatory challenges http://ijpsr.com/bft-article/regulatory-challenges-in-global-pharmaceutical-market/?view=fulltext

12.   Sterile formulation https://www.sciencedirect.com/science/article/pii/B9781455725533000180

13.   Sterile formulation http://www.cironpharma.com/new-plant-sterile-formulations.asp

14.   15 Chien YW. Ocular drug delivery and delivery systems. In: Novel Drug livery Systems, Marcel Dekker, New York.1996; 269-270.

15.   Markel dekker, Dilip MP, Hand book of pharmaceutical granulation technology, 1989, Newyork, 1989, 237‐260

16.   Sreenivas S.A, Gadad AP Formulations and Evaluation of ondansetron HCL directly compressed mouth disintegrating tablets, Indian drugs, 2006, 43(1), 35‐38.

17.   Lau E.2001.Preformulation Studies.In: Ahuja S, Stephen S, editors. Handbook of Modern Pharmaceutical Analysis, Vol 3.New York: Separation Science and Technology Academic Press, pp 173-224.

18.   Q2 (R1) Validation of Analytical Methods, Text and Methodology, ICH of Technical Requirements for Registration of Pharmaceuticals for Human Use.2005.

19.   Rajan VK, Garg S. Compatibility studies between Isosorbide mononitrate and selected excipients used in the development of extended release formulations.  J. Pharm. Biomed Anal. (2004) 35: 449-58.

20.   Maryadele JON. The Merck Index 14 th ed., 2006, Merck andCo Inc., New Jersey.

21.   Hite M. Part 1 The Oral Delivery of Poorly Soluble Drugs. PMPS. The research and product development group at SCOLR Inc. 2003

22.   Aulton ME. Pharmaceutics The scientific principles of dosage form design. 2nd ed: Churchill Livingstone; 2002.256-260.

23.   Maaike K, Leonard K. Lipoproteins - Role in Health and Diseases. Prof. Gerhard Kostner (Ed).Intech open.2012.

24.   Martins LA, Meneghini LZ, Junqueira CA, Ceni DC, Bergold A. A simple HPLC-DAD method for determination of adapalene in topical gel formulation. J Chromatogr Sci. 49(10); 2011 :796-800.

 

 

Received on 25.07.2019                                   Modified on 14.10.2019

Accepted on 08.11.2019                                 © RJPT All right reserved

Research J. Pharm. and Tech 2020; 13(3): 1511-1516.

DOI: 10.5958/0974-360X.2020.00275.9